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US Expands Venezuela Sanctions: Three Key Questions Answered

New restrictions prohibit dealings between US persons and the Government of Venezuela. On August 5, 2019, President Trump issued Executive Order (E.O.) 13884, entitled “Blocking the Property of the Government of...more

OFAC’s 5 Essential Components of an Effective Sanctions Compliance Program

OFAC outlines baseline considerations for evaluating a risk-based sanctions compliance program. On May 2, 2019, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published A Framework for OFAC Compliance...more

OFAC Imposes Comprehensive Sanctions on Venezuela’s State Oil Company, PdVSA

OFAC adds PdVSA to its sanctions list and simultaneously issues general licenses temporarily allowing certain transactions and activities involving PdVSA. On January 28, the US Treasury Department’s Office of Foreign...more

OFAC Adds Venezuela Media Company and Others to US Sanctions List

OFAC added several parties to the SDN List and simultaneously issued a General License, authorizing certain wind-down activities until January 8, 2020. Today, the Treasury Department’s Office of Foreign Assets Control...more

Top 10 Things to Know About Expanded US Sanctions on Iran

Withdrawal from the Iran nuclear agreement triggers full implementation of US sanctions, including threat of “secondary” sanctions on non-US persons dealing with Iran. As reported in the Latham Client Alert dated May 10,...more

EU Responds to the Snap-Back of US Sanctions Against Iran: Between a Rock and a Hard Place

In light of the EU’s recent amendments to its long-standing blocking measure, EU operators will need to weigh the consequences of failing to comply with their contradicting obligations under US and EU law. How has the EU...more

Top 10 Things to Know About President Trump’s Decision to Withdraw from the Iran Nuclear Agreement

Withdrawal from the JCPOA will lead to re-imposition of several categories of US sanctions. On May 8, 2018, President Trump announced that the United States will withdraw from the Joint Comprehensive Plan of Action...more

US Treasury Department’s New Designations Under the Russia-Related Sanctions: 3 Key Takeaways (Russian version)

The new designations of Russian individuals and entities broadly expand the scope and impact of sanctions. Background - On April 6, 2018, the US Treasury Department’s Office of Foreign Assets Control (OFAC) added more...more

US Treasury Department’s New Designations Under the Russia-Related Sanctions: 3 Key Takeaways

The new designations of Russian individuals and entities broadly expand the scope and impact of sanctions. Background - On April 6, 2018, the US Treasury Department’s Office of Foreign Assets Control (OFAC) added more...more

US Treasury Department Issues Anticipated List of Russian Parties, Pursuant to Recent Legislation (Russian)

Treasury Department Report identifies 114 senior political figures and 96 oligarchs, and confirms that the Report is not a sanctions list - On January 29, 2018, the Treasury Department submitted a report to the US Congress...more

US Treasury Department Issues Anticipated List of Russian Parties, Pursuant to Recent Legislation

Treasury Department Report identifies 114 senior political figures and 96 oligarchs, and confirms that the Report is not a sanctions list - On January 29, 2018, the Treasury Department submitted a report to the US...more

Venezuela Restructuring: A Long Road Ahead?

Venezuela’s initiative is unlikely to set the stage for a restructuring of international obligations in the face of US sanctions. Key Points: - US sanctions will prohibit US persons from engaging in a restructuring of...more

Expanded Russia, Iran, and North Korea Sanctions; Top 10 Takeaways (Japanese Translation)

President Trump signs the “Countering America’s Adversaries Through Sanctions Act,” which — among other measures — requires Congressional review to ease Russia-related sanctions. On Wednesday, August 2, 2017, President...more

The Trump Administration’s New Venezuela Sanctions: Top 10 Takeaways

President Trump issues an Executive Order prohibiting certain transactions involving the Venezuelan government and state-owned or state-controlled entities. Key Points: ..The Executive Order imposes new sanctions that...more

US Department of Justice Guidance Seeks to Encourage Voluntary Self-Disclosure of Export Controls and Sanctions Violations

The Guidance parallels the DOJ approach under the FCPA, but does not specify the value of mitigation and may create contradictory incentives. The National Security Division (NSD) of the US Department of Justice (DOJ)...more

Six Months After Implementation of Iran Nuclear Agreement: Top 10 Observations

Various factors continue to shape and limit trade and investment between Iran and the rest of the world. Six months have passed since the implementation of the nuclear agreement with Iran, officially known as the Joint...more

Top 10 Things to Know About the Implementation of the Iran Nuclear Agreement

The EU and UN terminate most of their sanctions on Iran, while the US implements more limited changes to its longstanding embargo. On January 16, 2016, the International Atomic Energy Agency (IAEA) verified that Iran...more

Movement Towards Implementation of Iran Nuclear Agreement Brings Limited Easing of Sanctions into Focus

Recent and upcoming milestones fuel expectations of Iran opportunities in 2016. As reported in our Client Alert dated July 16, 2015, the Joint Comprehensive Plan of Action (JCPOA) provides for the eventual termination of...more

Cuba Sanctions: 10 Important Changes

Ten key changes to US sanctions and export regulations for Cuba. On January 15, 2015, the Departments of the Treasury and Commerce revised the Cuban Assets Control Regulations (CACR) and the Export Administration...more

Sanctions Update: Continuing Implementation of US Embargo of Crimea Region

New US rules define scope of prohibitions and authorized activities, as Crimea region remains subject to broad US embargo and EU trade and investment restrictions. On January 29 and 30, 2015, the US Department of...more

Ukraine Crisis Update: US and EU Expand Sanctions, Restrict Certain Energy-Related Exports to Russia

US extends sanctions to three Russian banks, a shipbuilding company and exports of energy sector items to Russia; EU announces similar measures. Additional OFAC Designations - On July 29, 2014, the U.S....more

Ukraine Crisis Update: US Imposes New Sanctions on Major Russian Banks and Energy Companies

US announces “sectoral” sanctions on major banks and energy companies, adds to the Specially Designated Nationals list; European Council considers additional sanctions. On July 16, 2014, the U.S. Department of the...more

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